Despite the requirement to issue e-invoices, many businesses continue to receive PDF invoices. In most cases, this is currently permitted. This article explains when a PDF is still acceptable.

Introduction

The e-invoicing requirement has been in force since 2025 – and yet PDF invoices are still arriving. This is causing uncertainty for many. We’ll clarify for you whether this is permitted.

The answer in a nutshell: During the transition period (until 1 January 2027/1 January 2028) and in certain permanent exceptional cases, PDF invoices are still permitted. Whether a PDF is acceptable depends on who sends it and when.

These two factors – the sender and the timing – are the central theme of this article. They determine whether a PDF is still acceptable.

This article explains the transitional rules from the recipient’s perspective, the permanent exceptions and why you cannot refuse to accept e-invoices.

During the transition period, PDFs remain permissible

The main reason you are still receiving PDFs is the phased introduction.

Whilst the obligation to receive e-invoices has been in force since 2025, your suppliers are only required to issue e-invoices gradually.

The obligation to issue e-invoices will be phased in: from 1 January 2027 for businesses with a total turnover exceeding 800,000 euros in 2026, and from 1 January 2028 for all others.

Until then, a supplier may continue to send you a PDF invoice – but only with your consent. We will cover the deadlines separately:

Cases where PDF invoices are permanently permitted

In addition to the transitional period, there are cases where a PDF remains permanently permissible – regardless of the year. An e-invoice is never required in these cases.

• Small businesses: Anyone making use of the small business scheme is permanently exempt from issuing e-invoices and may continue to use PDFs or paper.
• Invoices to private individuals: There is no obligation to issue e-invoices when dealing with private customers.
• Small amounts up to 250 euros: Invoices for small amounts are exempt.
• Certain tax-exempt services: Here, too, e-invoicing is not mandatory.

When a PDF is no longer sufficient

The situation is different if your supplier is obliged to issue e-invoices and no exemption applies. In that case, a PDF is no longer sufficient.

Where an e-invoice is required, a PDF is regarded as a ‘other’ invoice and, in principle, does not entitle you to input tax deduction until it has been duly corrected as an e-invoice. During the transition period, such a discrepancy in format does not automatically result in the denial of input tax deduction; however, you should not rely on this. If, after the deadline has passed, you continue to receive PDFs from a supplier who is obliged to issue e-invoices, you should raise the issue of e-invoicing with them.

You cannot refuse to accept it

A clarification in the other direction: even if you yourself would prefer to stick with PDFs – if a supplier sends you an e-invoice, you must accept it.

Since 2025, the obligation to accept e-invoices has been in force without a transition period. You cannot refuse to accept them, nor can you insist on continuing to receive only PDFs. At the very least, an email inbox is sufficient for receiving e-invoices. We cover how to receive e-invoices and make them readable in a separate section.

Submission to us

Please forward both types to us: PDF invoices in the usual format and e-invoices in their original structured format.

The transfer takes place via the method agreed with us, such as DATEV Unternehmen Online or another document exchange platform. For e-invoices, we need the original file, not just a printout.

Common sources of error

• PDFs generally considered inadmissible: It is assumed that all PDFs will be prohibited from 2025. However, they remain permissible during the transition period and in exceptional cases.
• E-invoices not requested from suppliers subject to the obligation: After the deadline has passed, PDFs continue to be sent without any follow-up. This may jeopardise the input tax deduction.
• Receipt rejected: An incoming e-invoice is rejected because PDFs are preferred. It is not possible to reject receipt.
• Consent overlooked: A PDF is taken for granted without express or implied consent. During the transition period, the recipient’s consent is a prerequisite.
• E-invoice only passed on as a printout: An incoming e-invoice is printed out and passed on. We require the original structured file.

Frequently asked questions

Legal notice

This article provides an overview and does not constitute individual advice. Whether a PDF is acceptable in a specific case depends on the circumstances; the current legal situation is decisive.

If you have any questions regarding incoming invoices, please contact us directly.

As at: June 2026